IP High Court, 2022 (Gyo-Ke) 10118 — Program: A Disclaimer Claim and Inventive Step (Honda)
Updated: 2 days ago
Article information
Article type: Case note
Categories: Patents
Topics: Inventive step
First published on this website: 2026-10-16
Display and classification checked: 2026-10-17
Case information: 2022 (Gyo-Ke) 10118
IP High Court, 2022 (Gyo-Ke) 10118 — Program (Honda)
Claim: “… a control device … wherein the device to be controlled has a speaker but is not a television …”
No particular technical significance was found in the fact that the device controlled in the cited invention was a television.
⇒ Inventive step: denied. (The tactic of excluding an essential part of the cited invention through a disclaimer claim failed.)
(Excerpt from the decision)
In technology for controlling electronic devices using wireless communication, the specific nature of the controlling device … and of the device to be controlled (for example, whether it is a television …) cannot be recognized as having particular technical significance. … Considering also that the technologies corresponding to the respective technologies cannot be found to exclude cases involving devices other than the specific devices described in each publication, … identifying the publicly known technology described in Exhibit Ko 4 without limiting the controlling device and the controlled device to particular devices (respectively, digital camera 3 and high-definition television 1) cannot be regarded as an unjustified abstraction or an excessive generalization to a broader concept. (Additionally, … the description in the application’s specification is itself understood to presuppose that there is no difference in technical significance depending on whether the controlled device is a device with a speaker that is not a television, or is a television.) If the controlling device and the controlled device are not limited to particular devices, it is naturally also permissible to identify the publicly known technology in Exhibit Ko 4 without limiting the place of operation and the content of operations rendered ineffective to the particular place and particular content of the operations described. …
Originally published: 2025-03-17
Original Japanese post: https://ameblo.jp/hideki-takaishi/entry-12890243998.html
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2026-10-16: The AMEBLO source was first published on this website.
2026-10-17: Added classification, topic tags, article information, translation navigation, related articles, consultation guidance, and SEO. The original article text was not changed.
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